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Permanent Establishments

Arun Birla of Covington & Burling reports on a recent IFA Technical Meeting
The International Fiscal Association British Branch met on 22 April to discuss current issues relating to permanent establishments (PEs). The Chairman Jonathan Schwarz said that the purpose of the meeting was to look at the domestic rules after their first year in force and recent developments.
This was a thought-provoking session for the audience (which included members of the Inland Revenue). It was particularly timely given that the attribution of profits to PEs is a current 'hot topic'.
The first speaker was Dr John Neighbour Head of Transfer Pricing Tax Treaty & Financial Transactions (TTP) Division Centre for Tax Policy and Administration OECD. Being in a perfect position...

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